Limitation under income-tax reassessment turns on the assessment year, not the accounting year, under the statutory scheme.

For limitation under section 34(1)(a) of the Indian Income-tax Act, the phrase "for any year" was construed in the context of the Act's charging and assessment scheme, including the return-filing requirement and the assessment structure. The reference was taken to mean the assessment year, not the accounting year, because income is assessed by reference to the assessment year even when it arises from the previous year. This reading also avoided inconsistent limitation periods across different heads of income. On that basis, the notice and reassessment proceedings were treated as being within time.

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Issues: Whether, for the purpose of limitation under section 34(1)(a) of the Indian Income-tax Act, the words "for any year" refer to the assessment year or the accounting year.

Analysis: Section 34(1)(a) was read with the charging scheme of the Act, including section 3, the return-filing requirement under section 22(1), and the rate and assessment structure under the Indian Finance Act, 1948. The scheme showed that income was assessed for the assessment year, even though it related to income of the previous year. The reference in section 34(1)(a) to a return under section 22 for any year and to full and true disclosure for assessment of that year was therefore understood as a reference to the assessment year. A contrary reading would create different limitation starting points for different heads of income, which was inconsistent with the legislative scheme.

Conclusion: The words "for any year" in section 34(1)(a) mean the assessment year and not the accounting year. The notice and reassessment proceedings were therefore within time and the challenge to them failed.

Ratio Decidendi: For limitation under section 34(1)(a), the relevant year is the assessment year, because the Act ties notice, return, and reassessment to the assessment process rather than to the accounting year.

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